ML25212A146
| ML25212A146 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 08/05/2025 |
| From: | Eric Michel NRC/RGN-II/DFRSS |
| To: | Markle H BWXT |
| References | |
| IR 2025002 | |
| Download: ML25212A146 (1) | |
Text
Howard Markle Vice President and General Manager Nuclear Operations Group, Inc.
BWXT Nuclear Operations Group, Inc.
P.O. Box 785 Lynchburg, VA 24505-0785
SUBJECT:
BWXT NUCLEAR OPERATIONS GROUP, INC. - INTEGRATED INSPECTION REPORT 07000027/2025002
Dear Howard Markle:
On June 30, 2025, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at BWXT Nuclear Operations Group, Inc. On July 14, 2025, the NRC inspectors discussed the results of this inspection with Richard Freudenberger and other members of your staff. The results of this inspection are documented in the enclosed report.
No violations of more than minor significance were identified during this inspection.
This letter, its enclosure, and your response (if any) will be made available for public inspection and copying at http://www.nrc.gov/reading-rm/adams.html and at the NRC Public Document Room in accordance with Title 10 of the Code of Federal Regulations 2.390, Public Inspections, Exemptions, Requests for Withholding.
Sincerely, Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security Docket No. 07000027 License No. SNM-42
Enclosure:
As stated cc w/ encl: Distribution via LISTSERV August 5, 2025 Signed by Michel, Eric on 08/05/25
SUNSI Review X
Non-Sensitive
Sensitive X
Publicly Available
Non-Publicly Available OFFICE RII/DFRSS RII/DFRSS RII/DFRSS RII/DFRSS NAME N. Pitoniak C. Oelstrom M. Doyle E. Michel DATE 07/31//2025 07/31//2025 08/01/2025 08/05/2025
Enclosure U.S. NUCLEAR REGULATORY COMMISSION Inspection Report Docket Number:
07000027 License Number:
SNM-42 Report Number:
07000027/2025002 Enterprise Identifier:
I-2025-002-0034 Licensee:
Nuclear Operations Group, Inc.
Facility:
BWXT Nuclear Operations Group, Inc.
Location:
Lynchburg, VA Inspection Dates:
April 01, 2025, to June 30, 2025 Inspectors:
M. Doyle, Senior Resident Inspector J. Grice, Fuel Facilities Project Inspector C. Oelstrom, Fuel Facilities Project Inspector J. Raudabaugh, Fuel Facilities Project Inspector C. Taylor, Senior Fuel Facility Project Inspector Approved By:
Eric C. Michel, Chief Fuels Oversight Branch 2 Division of Fuels, Radiological Safety, and Security
2
SUMMARY
The U.S. Nuclear Regulatory Commission (NRC) continued monitoring the licensees performance by conducting an integrated inspection at BWXT Nuclear Operations Group, Inc.,
in accordance with the fuel cycle facility inspection program. This is the NRCs program for overseeing the safe operation of licensed fuel cycle facilities.
Refer to https://www.nrc.gov/materials/fuel-cycle-fac.html for more information.
List of Violations No violations of more than minor significance were identified.
Additional Tracking Items Type Issue Number Title Report Section Status WER 07000027/2024-001 Radioactive Material Shipped to Recycle Center (EN 57251) 86740 88030 Closed
3 PLANT STATUS During the inspection period, routine fuel manufacturing operations and maintenance activities were conducted in the fuel processing areas, the uranium recovery (UR) facility, and the research and test reactors (RTR) facility.
INSPECTION SCOPES Inspections were conducted using the appropriate portions of the inspection procedures (IPs) in effect at the beginning of the inspection unless otherwise noted. Currently approved IPs with their attached revision histories are located on the public website at http://www.nrc.gov/reading-rm/doc-collections/insp-manual/inspection-procedure/index.html. Inspections were declared complete when the IP requirements most appropriate to the inspection activity were met consistent with Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program. The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel to assess licensee performance and compliance with Commission rules and regulations, license conditions, site procedures, and standards.
SAFETY OPERATIONS 88020 - Operational Safety The inspectors evaluated selected aspects of the licensees Operational Safety program to verify compliance with selected portions of 10 Code of Federal Regulations (CFR) 70, including 70.61, and 70.62, as well as Chapter 11, Management Measures, of the facilitys license application, and applicable licensee procedures.
Identification of Safety Controls and Related Programs (IP Section 02.01)
The inspectors selected specific process areas for inspection based on the safety basis information of the facility, the risk/safety significance of the process areas, the description of plant changes submitted to the NRC, and past plant performance documentation. For the process areas of interest, the inspectors selected a sample of accident sequences in nuclear criticality safety and chemical safety based on the information provided in the safety analysis report (SAR) and other safety basis documentation. The inspectors conducted a general plant tour of each major plant operating area. The process areas and accident sequences selected for review are listed below:
Accident Sequences in Specialty Fuels Facility (SFF) SAR 15.17 and 15.18 specifically for the following workstations (WS) and accident sequences:
o WS 260: 3-1, 4A-1, 2a, 2b, 2c, 2d, 2f, 3, 4, 5a, 5b, 6, 8, 9, 10, 4B-1, and 4C-1 o
WS 100: 100-2, 100-4, 100-5, 100-7, 100-11, 100-3, 100-1, 100-17, SFF-2, 100-8, 100-18, 100-6a, 100-20, 100-16, 100-20, 100-19, and 100-6a o
WS 110: 110/160-2, 110/160-4, 110/160-8, 110/160-1, 110/160-7, 110/160-9, and SFF-1 o
WS 145: -3a-8k, 145-3a-9a1, 145-6-1d, 145-3a-4a, 145-6-1b1,145 1c, 145-3a-4b, 145-6-1a, 145-3a-9c, 145-3a-2b, 145-3a-2c,145-3a-1a, and 145-3a-8e
4 o
WS 30: 7-1, 2, 3, 4, 5, and 6 o
Solution Storage Columns: 31-2a, 31-2b, 31-4A, 31-4b, 31-6a, 31-7, 31-8c, 31-9a, 31-11,31-12a, 31-12b, 31-13, and 31-9b Review of Safety Controls and Related Programs (IP Section 02.02)
The inspectors reviewed information related to administrative, engineered, and passive safety controls or items relied on for safety (IROFS) for the accident sequences selected above, including the identification of the licensees assumptions and bounding cases as they apply to each of the selected accident sequences, safety controls, or IROFS. This review was performed to verify that the controls or IROFS were available and reliable to perform their intended safety functions and that the design basis assumptions were reflected in the actual conditions in the field. The specific safety controls selected for review are listed below:
Reviewed active engineered, passive engineered, and administrative IROFS for nuclear criticality and chemical accident sequences for the above process areas and workstations Implementation of Safety Controls (IP Section 02.03)
For the selected safety controls listed above, the inspectors reviewed management measures to verify proper implementation in accordance with 10 CFR 70 and applicable sections of the license application. This review was performed to verify that selected nuclear criticality safety (NCS) controls or IROFS were present, available, and reliable to perform their safety function and that the design basis assumptions were reflected in the actual conditions in the field. The inspectors conducted the following activities to verify the implementation of selected safety controls:
Walked down the following workstations of the SFF to verify components and implementation of criticality and chemical IROFS:
o Workstation 100 o
Workstation 145 o
Workstation 260 o
Workstation 30 o
Solution Storage Columns Reviewed NCS-2023-053 for justification of continued operation of SFF waste inline monitoring system Reviewed Safety Evaluation Request (SER)-022 for the repurposing of the backup raffinate columns Reviewed the following procedures for implementation of IROFS requirements in the above areas and workstations:
o OP-0061234 o
OP-0661131 o
OP-1001775 o
OP-1001827 o
OP-1001828 o
OP-1014602 o
OP-1014613 o
OP-1014625
5 o
OP-1015277 o
Reviewed NCS postings for IROFS for the above workstations in the SFF Safety Control Support Programs (IP Section 02.04)
The inspectors assessed additional management measures that support the availability and reliability of the selected safety controls to verify these were implemented in accordance with 10 CFR 70 and applicable portions of Chapter 11 of the license application. Specifically, the inspectors conducted the following:
Reviewed maintenance plans, work orders, and operating procedures listed in the documents reviewed for the IROFS associated with the above process areas and workstations Reviewed Corrective Action Program (CAP) entries/documents for the SFF, including:
o CA202400764 o
CA202400842 o
CA202401033 o
CA202402562 o
CA202500140 Reviewed organizational changes to verify changes are in accordance with license application Attended shift turnovers meeting Interviewed managers to verify daily and weekly checks are performed in accordance with procedures Reviewed internal audits BWIA-2024-R002 and BWIA-2024-R010 Reviewed quarterly self-assessments from year 2023 Reviewed training qualification records for and interviewed SFF operators for WS - 100/110 and 145 Interviewed SFF operators to verify knowledge of applicable procedures, IROFS, and implementing controls 88135.02 - Plant Status The inspectors routinely conducted walkdowns of licensee areas; observed operators; material control and accounting (MC&A) and security force personnel; inspected postings and licensee guidance documents; interviewed plant personnel and discussed the results of operational and shift turnover meetings to gain insight into the status of facility activities; risk-inform the selection and implementation of the appropriate core IPs; and ensure compliance with regulatory requirements.
Radiation Work Permit (RWP) (IP Section 03.09)
The inspectors reviewed and observed the RWP listed below to determine whether the RWP contained the information required by Chapter 4, Radiation Safety of the license application; the Radiation Protection (RP) Manual; and implementing procedures:
RWP 25-0015, Prepare for installation of furnace equipment per SER 24-030, conducted during the second quarter of 2025
6 Annual Security and Emergency Preparedness Drills/Exercises (IP Section 03.10)
The inspector observed the licensees performance during the security force-on-force (FOF) tactical response exercise and emergency plan drill listed below to determine if they were being implemented in accordance with 10 CFR 70.22(I)(3) and/or 10 CFR 73.46(b)(9):
Security FOF tactical response exercise conducted on the evening of April 9, 2025 On May 21, 2025, the inspector observed the third shift emergency plan drill 88135.04 - Resident Inspection Program Operational Safety The inspectors evaluated whether the material condition and as-found configuration of selected site structures, systems, and components, documentation, personnel, and IROFS to verify compliance with 10 CFR Part 70, the license, the SAR and/or license application, and licensee policies and procedures; as well as to make a determination whether they were appropriate, available, and reliable to protect worker and public safety during normal, off-normal, and accident conditions.
Operations Safety Walkdown (IP Section 03.01)
The inspectors evaluated the operational safety of the systems and sub-systems of the listed processes associated with SAR 15.26, fuel pack assembly process.
The inspector performed a walkdown of SAR 15.26 with the responsible engineer The inspector reviewed management measures and IROFS of SAR 15.26 The inspector reviewed change documents associated with SAR 15.26 88135.05 - Resident Inspection Program Fire Protection (Annual/Quarterly)
The inspectors evaluated the operational status and material condition of fire protection systems, structures, and components to verify compliance with the fire protection program as described in Chapter 7, Fire Safety of the license application, and the National Fire Protection Association (NFPA) 801, Standard for Fire Protection for Facilities Handling Radioactive Materials, as required. The inspector also evaluated the onsite fire brigade training and drill performance to verify compliance with NFPA 600, Standard on Industrial Fire Brigades.
Fire Area Walkdown (IP Section 03.01)
The inspectors walked down and evaluated the fire area listed below:
Research and Test reactor bays 13-16 on May 2, 2025 Fire Brigade Drill Performance Sample (IP Section 03.02)
7 The inspectors evaluated the fire brigade drill performance described below:
On May 21, 2025, the inspector observed the BWXT fire brigade respond to a fire at the burn building during the second shift Eplan (emergency plan) drill. The inspector observed the fire brigade performing the following actions:
Two fire engines driven from station 1 to the burn building Rapid deployment of two 2.5" attack lines Connection of a fire engine to a fire hydrant Fire engine engineer establishment of a pump speed to ensure adequate water flow and pressure for the fire attack lines Initial fire attack team donning of bunker gear, self-contained breathing apparatus and other required safety gear Initial entry into the burn building using fire axes and Halligan bars Initial search and rescue of one simulated victim from the burn building Treatment of the rescued victim and a second victim outside the burn building by EMTs Initial attack and extinguishing of the fire Establishment of a reflash watch RP technicians and other fire responders establishment of a hot zone, warm zone, and cold zone for hazardous waste operations and emergency response (HAZWOPER)
RP survey and decontamination of the fire brigade initial attack team and fire victims Packaging of fire victims and transport offsite in ambulances 88135.17 - Permanent Plant Modifications The inspectors evaluated implementation of the configuration management system for facility changes or modifications to ensure that IROFS or other credited safety controls could adequately perform their intended safety function and that changes did not adversely impact the operability and safety of the facility.
Facility Change/Modifications (IP Section 03.01)
The inspectors reviewed the recovery inline monitor system upgrade to determine whether it was implemented in accordance with 10 CFR 70.72, Facility changes and change process.
Specifically, the inspectors reviewed the following:
The inspector observed the maintenance and pre-operational testing of recovery inline monitors The inspector performed a system walkdown of the new recovery inline monitors with the responsible engineer 88135.19 - Post Maintenance Testing The inspectors evaluated post-maintenance test activities to verify compliance with license application Chapter 11, Management Measures, and test procedures and/or work order (WO)
8 instructions to confirm functional capability of the IROFS and/or safety control following maintenance.
Post-Maintenance Testing (IP Section 03.01)
The inspectors reviewed the post-maintenance test listed below. Tests were either observed directly or test results were reviewed.
WO20385181, six-month preventative maintenance (PM) for contactor "A",
aqueous feed filter - high pressure alarm and interlock test on April 30, 2025.
88135.22 - Surveillance Testing The inspectors evaluated IROFS and safety controls that required periodic surveillance and/or calibration tests to ensure they were available and reliable to perform their function when needed, to comply with license application Chapter 11, Management Measures, and the performance requirements of 10 CFR 70.61 and 70.62, and to maintain their operational readiness consistent with the Integrated Safety Analysis.
Surveillance and Calibration Testing (IP Section 03.01)
The inspectors reviewed the surveillance and/or calibration tests listed below. Tests were either observed directly or test results were reviewed.
Leak test on Tri-Structural Isotropic (TRISO) coating furnace WS-350, on June 9, 2025 RADIOLOGICAL CONTROLS 86740 - Inspection of Transportation Activities The inspectors evaluated select aspects of the licensees Transportation Activities Program to determine whether the licensee had established and maintained an effective, management-controlled program; to ensure radiological and nuclear safety in the receipt, packaging, delivery to a carrier and, as applicable, the private carriage of licensed radioactive materials; and to determine whether transportation activities are in compliance with the applicable portions of 10 CFR Parts 20 and 71, as well as the Department of Transportation (DOT) 49 CFR Parts 171-178.
Preparation of Packages for Shipment (IP Section 02.01)
The inspectors examined the licensees procedures and shipment records and observed actual package preparations and operations to verify compliance with the regulations above.
Specifically, the inspectors reviewed, verified, and observed the following:
Quality Work Instruction 15.5.5, Shipment of Radioactive Materials RMS-01, Identification and Communication Requirements for Shipment of Radioactive Material
9 RMS-02, Package Selection and Use for Shipment of Radioactive Material Reviewed shipment documentation for two dry active waste shipments (DAW) including o
Determinations o
Package marking o
Package labeling o
Package markings o
Radiological contamination and dose surveys for DAW containers and truck Delivery of Completed Packages to Carriers (IP Section 02.02)
The inspectors examined the licensees procedures and shipment records and observed actual transport operations/activities to determine that the licensee met package delivery requirements. Specifically, the inspectors reviewed or observed the following:
Two shipment records for DAW Two shipment records for advance test reactor (ATR) fuel Three shipment records for ES-3100 Observed DAW shipment preparations Receipt of Packages (IP Section 02.03)
The inspectors examined the licensees procedures and records of incoming shipments to verify compliance with 10 CFR 20.1906 and applicable license requirements. Specifically, the inspectors reviewed the following:
Two shipment records for DAW Two shipment records for ATR fuel Three shipment records for ES-3100 Receipt of type 7A drums Receipt of type B ES-3100 Records and Reports (IP Section 02.04)
The inspectors examined the licensees procedures and records for recordkeeping and reports to verify compliance with the regulations above. Specifically, the inspectors reviewed the following:
Approval and certification packages for 5-gallon 7A drums Approval and certification packages for 10-gallon 7A drums Approval and certification packages for 30-gallon 7A drums Approval and certification packages for 55-gallon 7A drums
10 General License Requirements (IP Section 02.05)
The inspectors reviewed the licenses utilized for shipment of radioactive material packages to verify compliance with 10 CFR 71, Subpart C. Specifically, the inspectors reviewed:
Certificate of Compliance (CoC) - 5797 CoC - 9390 CoC - 9330 Quality Assurance Program Approval No.088 Indoctrination and Training Program (IP Section 02.07)
The inspectors conducted interviews, reviewed training and indoctrination documentation, as well as observed activities for workers involved in transport activities to verify compliance with Chapter 11 of the licensee application. Specifically, the inspectors:
Interviewed the following personnel:
o Measurement and Control Transportation Unit Manager o
Three Transportation Administrators o
One technician Conducted a walkdown of a DAW shipment Conducted a walkdown of Bay 17 packages Conducted a walkdown of ATR inserts Quality Assurance Program (IP Section 02.08)
The inspectors reviewed the quality assurance documents to verify compliance with the licensees quality assurance (QA) program. Specifically, the inspectors reviewed:
QAP-0088 QWI-15.1.5 QWI-6.1.13 RMS-01 RMS-02 RMS-16 RMS-17 OP-1000312 RP-09 Audit Program (IP Section 02.09)
The inspectors reviewed the latest audit and/or assessment reports to verify compliance with 10 CFR 71.137. Specifically, the inspectors reviewed:
Audits o
IA-NMC-2023-08-01 o
BWAI-2024-R009 o
BWAI-2024-R007 o
IA-NMC-2022-08-01
11 Procurement and Selection of Packaging (IP Section 02.10)
The inspectors examined the licensees packaging, including those provided by a vendor and revised procedures and records to verify compliance with the Federal regulations above. Specifically, for packaging that is used by the licensee to transport or to deliver licensed material to a carrier for transport, the inspectors reviewed the following:
Observed the following packages o
type A 55-gallon drums o
USA/9390/B(U)F-96 o
USA/9330/AF-96 o
USA/5797/B(U)F Preparation of Packages for Shipment (IP Section 02.11)
The inspectors examined the licensees package markings, documentation, and records to verify compliance with applicable parts of the regulatory requirements above. Specifically, the inspectors conducted the following activities:
Walkdown DAW shipment and reviewed package markings Walkdown of Bay 17 to review ES-3100 and ATR package markings Reviewed advance notifications for the following shipping packages Two shipment records for DAW o
Two shipment records for ATR fuel o
Three shipment records for ES-3100 Periodic Maintenance of Packaging (IP Section 02.12)
The inspectors examined the licensees procedures and records to verify compliance with applicable parts of the regulatory requirements above. Specifically, the inspectors reviewed the following:
Not applicable. BWXT does not perform maintenance on reusable containers.
Records, Reports, and Notifications (IP Section 02.13)
The inspectors reviewed the licensees records and procedures for recordkeeping and reports to verify that a system is in place to verify compliance with the regulatory requirements above. Additionally, the inspectors followed up on an event notification (EN) related to a shipment of mixed metals. Specifically, the inspectors reviewed the following:
Quality records and procedures Two shipment records for DAW Two shipment records for ATR fuel Three shipment records for ES-3100 RMS-01 RMS-02
12 RMS-16 RMS-17 OP-1000312 RP-09 EN 57251 Corrective Action CA 202401144 88030 - Radiation Protection The inspectors evaluated selected aspects of the licensees RP program to verify compliance with selected portions of 10 CFR 19, 20, 40, 61 and 70, and Chapter 4, Radiation Protection, of the facilitys license application, and applicable licensee procedures.
Radiation Protection Program Review (IP Sections 02.01, 02.02, 02.03, 02.23)
The inspectors interviewed licensee staff and reviewed licensee procedures and other documentation related to the implementation of the RP, radiological waste (RW), and as low as reasonably achievable (ALARA) programs to verify compliance with 10 CFR 20.1101(a),
20.1101(b), 20.1101(c), 20.2102, 70.72, and Chapters 2 and 4 of the license application.
Specifically, the inspectors performed the following:
Radiation Protection/Waste Program Implementation and Procedures (IP Section 02.01 & 02.03)
Reviewed the Environmental Safety, Health, and Safeguards (ESH&S)
Organizational chart dated June 4, 2025, to verify functions and responsibilities remain independent from operations and production Reviewed RP-02-012, Guidelines for Handling Radiation Protection Radioactive Waste, Revision 06 Performed a walk through with a radiation safety technician in radiological waste areas within the following areas: Recovery, Downblending, Advanced Fuels and Drum Count Reviewed qualifications and training for new Waste Operations Unit Manager for the ESH&S organization Interviewed Waste Operations Unit Manager regarding daily waste responsibilities, independence from operations, and staffing levels Radiation Program Review and ALARA (IP Section 02.02 & 02.23)
Reviewed 2024 ALARA Report Reviewed monthly ALARA Meeting Reports from December 2023 to May 2025 Reviewed RP program Triennial Audit dated December 2024 Reviewed quarterly Lynchburg Technology Center (LTC) Health Physics Audits for 2024 and 2025 Reviewed qualifications for new Radiation Control Front Line Manager against requirements of license application; interviewed individual regarding daily radiation safety responsibilities, independence from operations, and staffing levels
13 Reviewed internal quality audits involving the following areas o
Internal exposure control o
ALARA Program - Nuclear Operations Group Lynchburg (NOG-L) and Lynchburg Technology Center (LTC) o Inspections, audits, and assessments o
Records and records retention o
Radioactive contamination control Training (IP Section 02.04)
The inspectors interviewed licensee staff and reviewed training records, training material, and training schedules to verify compliance with 10 CFR 19.12, and section 4 of the license application. Specifically, the inspectors:
Reviewed annual RadCon Tech (RCT) refresher training attendance records for 2024 and 2025 Reviewed RCT training materials Reviewed RadCon qualification training plans Reviewed RadCon qualification and special on the job training (SOJT) records for three employees Interviewed licensee staff regarding training and qualification process Safety-Significant Events (IP Section 02.05)
The inspectors reviewed the licensees review of safety-significant events, RP and radioactive waste related CAP entries to verify compliance with 10 CFR 20.2201, 20.2202, 20.2203, 70.50, 70.74, Part 70 Appendix A, and section 4.5 of the license application.
Specifically, the inspectors:
Reviewed the following corrective actions and supporting documents:
o CA202500584 o
CA202401250 o
CA202401048 o
CA202500512 o
CA202500506 o
CAR# C-2511 o
CA202401565 o
CA202500316 o
CA202401251 o
CA202401657 o
CA202401631 o
CA202401756 o
CA202401144 (EN 57251)
Reviewed RP-02-006, "Personnel Surveys and Decontamination," Rev.18 Reviewed LTC-QIP-32, "Quality Implementing Procedure," Rev. 10 Reviewed QWI 14.1.10, "Safety Evaluation of Unusual Incidents," Rev. 20 Reviewed EPR-03-14, "Radiological Assessment for Incidents Involving Radioactive Materials," Rev. 8
14 Reviewed QWI 14.1.01, "Preventive Corrective Action System," Rev. 45 Radiation Exposure Controls (IP Sections 02.06, 02.18)
The inspectors reviewed licensee's measures such as radiological work permits to control the concentration of radioactive material in air or limiting intake to keep doses ALARA to verify compliance with 10 CFR 20.1101(b), 20.1701, 20.1702, and applicable sections and Chapter 4 of the license application. Specifically, the inspectors interviewed licensee staff, observed activities/operations, and/or reviewed records related to the following:
Observed fixed air sampling collection Interviewed licensee staff regarding airborne radiation measurements Interviewed RP management regarding plant areas with the highest exposure potential to workers and ALARA efforts taken in those areas Reviewed RP-04-007, "The Collection and Analysis of Personal Air Samples",
Rev. 24 Reviewed RP-04-008, "Fixed Air Sampling", Rev 32 Reviewed procedure, RP-06, "Radiation Work Permit," Rev 15 Reviewed the following Radiation Work Permits (RWPs) o RWP 24-0073 o
RWP 24-0058 o
RWP 24-0055 o
RWP 24-0024 o
RWP 24-0043 o
RWP 24-0039 Walked down and observed individuals in the Recovery and Advanced Fuels areas working to RWPs 24-0024, 24-0043, and 23-0071 with appropriate plant protective equipment Instrument Calibration and Surveys (IP Sections 02.07, 02.08, 02.14, 02.15)
The inspectors reviewed licensees procedures and documentation for RP instrument calibration, radiation surveys, contamination control measures, use of radiation detecting instruments and equipment and interviewed licensee staff to verify compliance with 10 CFR 20.1501 and 70.24, 20.1902, 20.2103 and Chapter 4 of the license application. Specifically, the inspectors observed activities, reviewed documents, and/or interviewed licensee staff related to the following:
Instrument and Equipment/Calibration (IP Sections 02.07 & 02.08)
Reviewed RP-07-057, "General Procedure for Calibration and Control of Radiation Protection Instrumentation," Rev. 24 Reviewed RP-07, "Control and Use of Instrumentation," Rev 7 Interviewed staff at the onsite instrument calibration laboratory regarding training, tracking of sealed sources, and staffing Performed walkdown of the onsite instrument calibration laboratory and observed restricted access control for both entry doors and window bars in the area where sealed sources are secured, and fire-rated cabinets for instrumentation calibration records
15 Reviewed certificates stating that calibration sources were traceable to a National Institute of Standards and Technology (NIST) standard Reviewed calibration records for JL Shepherd Model 89-30 and 89-130 Calibration Units, RP-07-59; RP1694, 30 Ci and 100 Ci, semiannually; calibration dated: 01/11/2025 Reviewed criticality accident alarm system calibration records for criticality detectors 66 & 75 Reviewed calibration logs for radiation waste assay detection equipment Performed walkdown of step-off pads to verify friskers, and hand & foot monitors are calibrated in accordance with site procedure Reviewed calibration records for the following in-house laboratory equipment:
o RP 3625 - I-Matic; 01/23/2025 o
RP 3611 - I-Matic; 02/17/2025 o
RP 3612 - I-Matic; 02/05/2025 o
RP 3613 - I-Matic; 01/31/2025 Radiation Surveys & Contamination Control (IP Sections 02.14 & 02.15)
Reviewed Radiation Protection Manual, RP-07, Control and Use of Instrumentation Observed calibration labels were placed on survey instruments used at step-off pad locations Interviewed and observed radiation safety technician perform contamination smear samples in Recovery, Advanced Fuels and drum count area Reviewed RP-02, Radiation Protection Manual, "Contamination Control," Rev.
12 Reviewed RP-02-001, Safety Radiation Protection, "Contamination Control Procedure," Rev. 16 Reviewed RP-02-01, Form 10, Radiation Protection Manual, Designation of UR Smear Locations (U), Rev 18 Reviewed Smear Data List Report dated 05/01/2025 through 05/31/2025 -
Cafeteria Table (B091) UPRR-RTRT Reviewed Smear Data List Report dated 06/24/2025 for Recovery, MET, Advanced Fuels and drum count area Postings and Labeling (IP Sections 02.09, 02.10, 02.16)
The inspectors observed the posting and labeling of radiation areas, radioactive material storage areas, radioactive containers, and control of licensed sealed sources to verify compliance with 10 CFR 20.1902 and 20.1904, 20.1905, 20.1903 and Chapter 4 of the license application. Specifically, the inspectors performed the following:
Posting/ Container Labeling (IP Sections 02.09 & 02.10)
These inspection procedure sections were completed during routine inspection activities conducted throughout the year by the NRC senior resident inspector (SRI) under IP 88135 Sealed Sources (IP Section 02.16)
Reviewed Quality Work Instruction (QWI) 14.1.01, "Six Month Inventory Lynchburg Technology Center (LTC) Preventive Corrective Action System,"
Rev. 45
16 Interviewed LTC and onsite calibration laboratory staff regarding sealed source storage and access controls for sealed source tracking database Reviewed RP-15, "Control and Use of Sealed Radioactive Source," Rev. 06 Reviewed RP-15-001, "Radioactive Source Inventory and Tracking," Rev. 10 Reviewed six-month leak test records for LTC: Radiation Source Lead Test, RP-15-02, Form 1, Rev 6. LTC: date 12/06/2024 and 06/6/2025; Counting Instrument RP No. 2349 for the following sources:
o RP0033-Cs-137 o
RP0083-Am241: Be o
SO210-Ni-63 o
SO211-Ni-63 o
SO329-Cs-137 Posting of Notices (IP Section 02.11)
This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC SRI under IP 88135 This inspection procedure section was completed during routine inspection activities conducted throughout the year by the NRC SRI under IP 88135 Access Control (IP Section 02.12)
The inspectors observed/reviewed the licensees access control measures for radiation areas to verify compliance 10 CFR 20.1502(a)(4), 20.1601, 20.1602, other regulation and Chapter 4 of the license application. Specifically, the inspectors performed the following:
Interviewed staff and observed high radiation and very high radiation areas access and posting at the LTC in the cask cell area and spent fuel storage locations Performed walk downs of change rooms and step-off pads at access points between the contaminated and uncontaminated sides Licensed Material Control (IP Section 02.13)
The inspectors observed the licensees measures to secure stored material and control and maintain constant surveillance of licensed material not in storage to verify compliance with 10 CFR 20.1801, 20.1802 Specifically, the inspectors:
Observed the storage of licensed material in sealed geometrically favorable containers and racks Observed storage of sealed sources in the following areas:
o Onsite calibration lab o
LTC RadCon office
17 Dose Assessment Program (IP Sections 02.17, 02.22)
The inspectors interviewed licensee staff and reviewed records and calculations related to the licenses assessment and assignment of doses to workers to verify compliance with 10 CFR 20.1201, 20.1204, 20.1207, 20.1208, 20.1502(b), 20.2104, 20.2106 and section 4.3 of the license application. Specifically, the inspectors:
Interviewed licensee staff responsible for dose assessment regarding occupational dose trends Reviewed internal and external dose records for four employees Observed dose assessment tracking software Reviewed Radiation Protection Technical Work Record (RPTWR) Number 2024-009; review of air monitoring program in Preparation of NRC Form 5s for 2023, dated07/26/2024 Reviewed Internal Exposure Report (breathing zone data only): 01/01/2025 through 05/31/2025 Dosimetry Program (IP Sections 02.19, 02.20, 02.21)
The inspectors interviewed licensee staff and reviewed the implementation and documentation of the internal and external dosimetry programs including bioassay, whole body counting, and use of dosimetry in the field to verify compliance with 10 CFR 20.1502(a), 20.1502(b), 10 CFR 20.2103(b)(3) and Chapter 4 of the license application.
Specifically, inspectors interviewed licensee staff, and reviewed records related to the following:
Bioassay Program & Whole Body Counting (IP Section 02.19, 02.20, and 02.21)
Bioassay (IP Section 02.19)
The inspectors interviewed licensee staff and reviewed the bioassay program to verify compliance with 10 CFR 20.2103(b)(3), and license application section 4.3.4.
Specifically, the inspectors performed the following activities:
Interviewed licensee staff regarding the offsite contractors who analyze bioassay samples Reviewed urinalysis reports for individuals under the site bioassay program Reviewed the bioassay procedures:
o PR-04-010, Procedure for Handling Bioassay Samples, Rev. 15 o
RP-04-002, "Bioassay Sampling Program," Rev. 6 o
RP-04-006, "Bioassay Following an Incident," Rev. 12 o
RP-04-016, "Implementation of the LTC Bioassay Program," Rev, 9 o
RP-04-014, "Bioassay Quality Assurance Selection Criteria Independent Lab," Rev. 10 Walkdown main bioassay collection location on site and observed access controls and storage locations Interviewed radiation technician in charge of bioassay program regarding bioassay sample collection and chain of custody for samples Reviewed Radiation Protection Technical Work Record; RPTWR Number 2025-014; Spike, Blank Laboratory bioassay, urine, bias, dated 05/22/2025 Approved vendor list bioassays - BWXT NOG-L Supplier Quality Audit Report; Teledyne Brown Engineering; 01/24/2023
18 Approved vendor list bioassays - BWXT NoG-L Supplier Quality Audit Report; Gel Laboratories, 04/02/2024 Whole Body Counting (IP Section 02.20)
The inspectors interviewed licensee staff to verify compliance with license application section 4.3. Specifically, the inspectors:
Interviewed licensee staff regarding the whole-body counting program and determined the licensee had not performed whole body counts on site workers and contractors for several years because site action levels have not been exceeded. However, the licensee continues to maintain a contract and procedures for the whole-body counting program.
Reviewed RP-04-005, In-Vivo Counting, Rev 9 Dosimetry (IP Section 02.21)
Reviewed RP-03-001 "Issuance, Exchange, & Evaluation of Dosimetry", Rev.
24 Reviewed RP-03-009 "External Dosimetry Quality Contro,l" Rev. 11 Interviewed licensee staff regarding the various personal dosimeters in use Reviewed National Voluntary Laboratory Accreditation Program accreditation for the licensee's dosimeter processors Reviewed weekly exposure log for self-reading dosimeters at LTC dated 06/02/2025 and 06/23/2025 Reviewed LTC radiation dosimetry reports Reviewed LTC Area thermoluminescent dosimeter (TLD) Badge Dosimetry Reports Reviewed Ring Badge & Whole Body Dosimeter QC - Annual CY2024 report dated 03/27/2025 Observed staff from various areas appropriately wearing dosimetry INSPECTION RESULTS WER Radioactive Material Shipped to Recycle Center (EN57251)
WER 07000027/2024-001 86740
==
Description:==
During this inspection the inspectors reviewed Event Notification57251 with respect to a focus on radiation protection (Section 88030 - Radiation Protection) and transportation (Section 86740 - Inspection of Transportation Activities) aspects by reviewing corrective action documents associated with CA 202401144. The event involved the inadvertent shipment of radioactive material to a recycling vendor contracted to handle clean scrap aluminum material. The event occurred on July 29, 2024, and was reported to the NRC Operations Center in accordance with the requirements of 10 CFR 20.2202(b). In addition to the inspection areas identified above, the NRC completed reviews of the event and associated corrective actions with regard to the specific inspection areas of safety operations (ML25028A229), nuclear material control and accounting (ML24281A138), and physical security (ML25069A387) and this event has been dispositioned in accordance with regulatory requirements applicable to each specific inspection area. Details of the event and corrective actions contain Security-Related Information and will not be made publicly available in
19 accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390(d)(1). EN 57251 is closed.
EXIT MEETINGS AND DEBRIEFS The inspectors verified no proprietary information was retained or documented in this report.
On July 14, 2025, the inspectors presented the integrated inspection results to Richard Freudenberger and other members of the licensee staff.
20 DOCUMENTS REVIEWED Inspection Procedure Type Designation Description or Title Revision or Date CA 202300039 Water accumulation in 55 gallon drum 01/23/2023 Corrective Action Documents CA 202401144 Shipment of mixed metals sent to local recycling facility 07/29/2024 Quality Assurance Program Approval No. 0088 Rev.23 Multiple ES-3100 Receipt Package Multiple Type 7A drum receipt packages Multiple Type A 7A Drum procurements Certificate of Compliance No. 9330 (ATR)
Rev. 17 Certificate of Compliance No. 5797 (HFIR)
Rev. 23 SER for CoC No. 9330 Rev. 17 SER for CoC No. 5797 Rev. 23 Multiple ES-3100 shipment documents Multiple dry active waste (DAW) shipment documents Multiple ATR shipment documents Safety Evaluation Report for Certificate of Compliance No.
9390 Rev. 5 Miscellaneous Certificate of Compliance (CoC) No. 9390 (OPTIMUS-L)
Rev. 5 Training for OP-1000312 Rev. 30 Training roster for Transportation of Hazardous and Radioactive Materials and Training for the Safe Transport of Dangerous Goods by Air 07/03/2024 N-130 Functional Specification for NMC Waste System Rev. 11 OP-10001324 Operating Procedure for Inspection of fissile and Type B Shipping Containers and Spare Parts Rev. 11 OP-1000312 Operating Procedure for Tamper-Safing of SNM Stored on Site Rev. 30 OP-1003947 Operating Procedure for SGHX NDT Personnel Qualification and Training Rev. 17 QAP-0088 Quality Assurance Plan for Shipping Program Rev. 28 Quality Work Instruction 15.1.5 Shipment of Radioactive Materials Rev. 12 86740 Procedures QWI 6.1.13 Procurement of Materials Component s, and Services for Rev. 8
21 Inspection Procedure Type Designation Description or Title Revision or Date Radioactive Material Shipping Containers RMS-01 Identification and Communication Requirements for Shipment of Radioactive Material Rev. 10 RMS-02 Packages Selection and Use for Shipment of Radioactive Material Rev. 17 RMS-02 0 CSIR for C of C 9246, NIST Model ST Package Rev. 9 RMS-02 9 CSIR for C of C 5797, (INNER) HFIR Package Rev. 10 RMS-02 4 CUSIR for Drum Type Containers, DOT 7A and UNC-2600 Containers Rev. 8 RMS-02 6 CUSIR for C of C 9315, ES-3100 Package Rev. 28 RMS-02 9 CUSIR for HFIR Containers, C of C 5797 Rev. 8 RMS-02 7 CSIR for C of C 9315, ES-3100 Package Rev. 14 RMS-02 8 CSIR for C of C 9330, ATR Package (Including Cobra/BR2, MIT, MURR, RINSC, and Small Quantities)
Rev. 22 RMS-02 9 CUSIR for C of C 9330, ATR Package Including Cobra/BR2, MIT, MURR, RINSC, and Small Quantities Rev. 19 RMS-02, CSIR for LSA/SCO Packaging Rev.6 RMS-02, CSIR for Type A Uranium Packaging Rev. 7 RMS-16 Package Maintenance Rev. 12 RMS-21 Classification, Characterization, Packaging and Preparation of Low Level Radioactive Waste and mixed Waste Rev. 26 RMS-22 LSA Shipments Rev. 10 RMS-23 Low Level Radioactive Waste Administrative Procedure Rev. 11 RMS-26 Leak Testing Containers using the VTI System Rev. 2 RMS-27 NMC Shipment Procedure Rev. 3 RP-09 Transportation of Radioactive Materials Rev. 10 Self-Assessments BWAI-2024-R007 261-6B2 Nuclear Materials Control (Shipping Quality August 2024
22 Inspection Procedure Type Designation Description or Title Revision or Date Assurance Plan - 18 Elements)
BWIA-2024-R009 261-6B1, Nuclear Material Control (Radioactive Materials Transportation and Waste Disposal)
October 2024 IA-NMC-2022 01 261-6B2 Nuclear Material Control (Shipping Quality Assurance Plan - 18 Elements)
August 2023 IA-NMC-2023 01 258-3B Radiation Protection (Transportation and Waste Disposal at NOG-L and LTC) 261-6B1 Nuclear Materials Control (Radioactive materials Transportation and Waste Disposal)
October 2023 CA202400764 Material down sink 05/15/2024 CA202400842 WS 300 FAS went into Alarm 05/30/2024 CA202401033 Emergency stop did not function during testing 06/27/2024 CA202401562 Spacing does not meet required spacing 10/14/2024 Corrective Action Documents CA202500140 Column overflowed 01/30/2025 NCS-2006-024 Nuclear Safety Release for CR-1010748 02/03/2006 NCS-2023-036 Nuclear Safety Release for SER 20-040, Phase 1 04/24/2023 NCS-2023-053 Justification for Continued Operations of SFF Waste Inline Monitoring System 05/31/2023 NCS-2023-072 Nuclear Safety Release for SER 22-031 Phase 02 07/07/2023 NCS-2023-073 Nuclear Safety Release for SER 21-015 Phase 1 10/26/2023 Engineering Evaluations SER-022 Repurpose Back Up Raffinate Columns 02/20/2025 Training Qualification Records for SFF Operators Various Various NCS Postings Various M35-037 SFF Checklist Rev. 72 Miscellaneous NCS-2008-155 Workstation Verification Tables (Various) 07/28/2009 OP-0061234 Operating Procedure for Maintenance in UPRR Rev. 63 OP-0661131 Operating Procedure for Control of UPRR Supplies Rev. 15 OP-1001775 Operating Procedure for Liquid Storage Column System Rev. 18 OP-1001827 Operating Procedure for Waste/Scrap Handling and Disposal
- SFF Area Rev. 36 OP-1001828 FAS Interlocks and Furnace Testing Rev. 53 88020 Procedures OP-1014602 Operating Procedure for TRISO ADUN Solution Preparation at WS 260 Rev. 38
23 Inspection Procedure Type Designation Description or Title Revision or Date OP-1014613 Operating Procedure for Washing/Drying Operations for TRISO Fuel in WS 110 Rev. 15 OP-1014625 Rev. 25 OP-1015277 Fluid Bed Sintering in the CENTORR Furnace for TRISO Rev. 31 OP-1015720 Operating Procedure for Coating in the CENTORR Furnace for TRISO Rev. 53 OP-1046436 WS-350 TRISO Coating Furnace Operations Rev. 4 Audits, Inspections & Observation Summary - 1st, 2nd, 3rd, and 4th Quarter 2023 Various BWIA-2024-R002 Safety Analysis Report (SAR) 15.07 - General Purpose Reclamation Area Processes in Uranium Recovery February -
March 2024 Self-Assessments BWIA-2024-R010 Safety Analysis Report (SAR) 15.08 - Preparation of Chemical Reagents in Uranium Recovery November -
December 2024 MP# 1173 12/23/24 MP# 1301 09/18/2024 MP# 1886 02/25/2025 MP# 1973 04/07/2025 MP# 2074 07/02/2024 MP# 2538 01/07/2025 MP# 2539 01/07/2025 MP# 2542 01/13/2025 MP# 2550 01/31/2025 MP# 3611 01/31/2025 MP# 3612 01/31/2025 MP# 5129 02/27/2025 MP# 5198 02/28/2025 MP# 5243 04/11/2025 MP# 5244 04/11/2025 MP# 5245 04/08/2025 MP# 5246 04/08/2025 MP# 5273 02/24/2025 Work Orders MP# 5315 02/26/2025
24 Inspection Procedure Type Designation Description or Title Revision or Date MP# 5412 01/31/2025 MP# 5413 01/31/2025 MP# 5414 01/31/2025 MP# 5416 01/07/2025 MP# 5417 01/07/2025 MP# 5418 01/07/2025 MP# 5419 01/13/2025 MP# 5420 01/13/2025 MP# 5421 01/13/2025 MP# 5422 01/13/2025 MP# 5423 01/13/2025 MP# 5424 01/13/2025 MP# 5491 03/03/2025 MP# 5493 04/26/2024 MP# 5496 04/29/2024 MP# 5497 10/02/2024 MP# 5498 04/07/2025 MP# 5499 10/02/2024 MP# 5500 10/31/2024 MP# 5514 07/24/2024 MP# 5555 10/23/2024 MP# 5556 12/02/2024 MP# 5557 04/26/2024 MP# 5558 03/14/2025 MP# 5561 08/15/2024 CA202401251 CA202401565 CA202401631 CA202401657 CA202401756 Corrective Action Documents CA202500316 88030 Miscellaneous BWXT NoG-L supplier Quality Teledyne Brown Engineering 1/24/2023
25 Inspection Procedure Type Designation Description or Title Revision or Date Audit Report BWXT NoG-L supplier Quality Audit Report Gel Laboratories 04/2/2024 ID 14385 Internal Dose Assessments;24-005 10/31/2024 ID 6945 Internal Dose Assessments;24-002 08/16/2024 SRC2024-01 Safety Review Committee Meeting Minutes 04/10/2024 SRC2024-02 Safety Review Committee Meeting Minutes 07/10/2024 SRC2024-03 Safety Review Committee Meeting Minutes 10/14/2024 SRC2024-04 Safety Review Committee Meeting Minutes 01/14/2025 SRC2025-01 Safety Review Committee Meeting Minutes 04/28/2025 EPR-03-14 Radiological Assessment for Incidents Involving Radioactive Materials Rev. 8 RP-02-001 Safety Radiation Protection, Contamination Control Procedure Rev. 16 RP-04-010 Procedure for Handling Bioassay Samples Rev. 15 RP-07-057 General Procedure for Calibration and Control of Radiation Protection Instrumentation, Rev. 24 Quality Work Instruction (QWI) 14.1.01 Six Month Inventory (LTC) Preventive Corrective Action
- System, Rev. 45 Quality Work Instruction, QWI 14.1.01 Preventive/Corrective Action System, Rev. 45 RP-01 ALARA Rev. 11 RP-02 Contamination Control Rev. 12 RP-02-01, Form 10 Designation of URPS Smear Locations (U),
Rev. 18 RP-02-012 Guidelines For Handling Radiation Protection Radioactive Waste Rev. 06 RP-02-07 Enclosure Air Flow Measurements in Controlled Areas Rev. 11 RP-03 External Radiation Exposure Control Rev. 15 Procedures RP-04 Internal Exposure Control Rev. 17
26 Inspection Procedure Type Designation Description or Title Revision or Date RP-04-002 Bioassay Sampling Program Rev. 6 RP-04-005 In-Vivo Counting Rev. 9 RP-04-006 Bioassay Sampling Following an Incident Rev. 12 RP-04-014 Bioassay Quality Assurance Selection Criteria Independent Lab Rev. 10 RP-04-016 Implementation of the LTC Bioassay Program Rev. 9 RP-05 Respiratory Protection Rev. 16 RP-06 Radiation Work Permit Rev. 15 RP-07 Radiation Protection Manual Control and Use of Instrumentation Rev. 7 RP-12-005 Retention of Records & Procedures Rev. 12 RP-15 Control and Use of Sealed Radioactive Sources Rev. 06 RP-15-001 Radioactive Source Inventory and Tracking Rev. 10 RWP 24-0055 RWP 24-0024 RWP 24-0039 RWP 24-0043 RWP 24-0058 Radiation Work Permits (RWPs)
RWP 24-0073 BWIA-2024-R-005 Internal Audit Summary Report 05/23/2024 BWIA-2024-R001 Internal Audit Summary Report 01/08/2024 BWIA-2024-R004 Internal Audit Summary Report 04/22/2024 BWIA-2024-R006 Internal Audit Summary Report 06/26/2024 BWIA-2024-R011 Internal Audit Summary Report 12/02/2024 Self-Assessments RPTWR Number 2024-009 Radiation Protection Technical Work Record; Review of AMP in Preparation of NRC Form 5s for 2023 07/26/2023 Work Orders RPTWR Number2025-014 Radiation Protection Technical Work Record; Blank Laboratory Bioassay Urine 05/22/2025 CA202500470 NCS - UIR 04/05/2025 CA202500496 NCS - UIR 04/11/2025 CA202500506 RP - UIR 04/14/2025 88135.02 Corrective Action Documents CA202500512 RP - UIR 04/15/2025
27 Inspection Procedure Type Designation Description or Title Revision or Date CA202500528 RP - Regulatory 04/17/2025 CA202500585 NCS - UIR 04/28/2025 CA202500595 Other 04/29/2025 CA202500744 Chemical Processing 05/27/2025 CA202500815 Personnel Injury 06/08/2025 CA202500926 Other 06/28/2025 CA202500927 Work Instructions Incomplete / Incorrect 06/28/2025 Procedures OP-1001828 FAS Interlocks and Furnace Testing Rev. 53 Radiation Work Permits (RWPs) 25-0015 Prepare for installation and install furnace equipment per SER 24-030 Rev. 0 88135.04 Engineering Changes CHG-00015710 Changes to SAR 15.26, and SAR 15.26 Appendix 9/12/2024 88135.05 Fire Plans Section 11 Research and Test Reactors bays 13-16 04/06/2020 Calibration Records RP-07-115 Calibration of recovery inline 06/16/2025 Engineering Evaluations NCS-2025-056 Nuclear Safety Release for SER 24-017 Phases 1 Pre-Operational Requirements 06/19/2025 UPRR Test Plan Recovery Inline #1 06/19/2025 UPRR Test Plan Recovery Inline #2 06/19/2025 Procedures UPRR Test Plan Recovery Inline #3 06/19/2025 N-105 SER Release Record Rev. 08 WO 20391637 Testing of Recovery Inline #2 06/19/2025 WO 20391638 Testing of Recovery Inline #3 06/19/2025 88135.17 Work Orders WO 2039164 Testing of Recovery Inline #1 06/19/2025 88135.19 Work Orders 20385181 6-month PM and test for contactor "A" aqueous feed filter -
high pressure alarm and interlock test.
04/30/2025